Louisiana Land & Exploration Co. v. Commissioner
United States Tax Court
P is an affiliated group of corporations engaged primarily in exploration for, and development, production, refining, and sale of, oil and natural gas and exploration for, and production and mining of, other minerals. On Jan. 25, 1980, P entered into a joint operating agreement with 11 other participants to exploit certain oil and gas deposits in the North Brae development area of the North Sea.
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P is an affiliated group of corporations engaged primarily in exploration for, and development, production, refining, and sale of, oil and natural gas and exploration for, and production and mining of, other minerals. On Jan. 25, 1980, P entered into a joint operating agreement with 11 other participants to exploit certain oil and gas deposits in the North Brae development area of the North Sea. Under the joint operating agreement, P received a working interest in the oil and gas deposits. The exploitation of the oil and gas deposits required the construction, transportation, and installation…
1Opinion of the Court
Clapp, Judge:
Respondent determined deficiencies in petitioner’s Federal corporate income taxes as follows:
Year Deficiency
1984 . $36,646,062
1985 . 3,615,049
After concessions, the issues for decision are: (1) Whether the nonmaterial costs of fabricating certain modules that are structural components of an offshore drilling and production platform are properly deductible as intangible drilling and development costs (idc) under section 263(c); (2) whether the nonmaterial costs of installing certain equipment housed in such modules are properly deductible as idc under section 263(c); (3) whether,…
2Cases cited10 opinions
- Standard Oil Co. v. CommissionerUnited States Tax Court · 1981
- Union Carbide Corp. v. CommissionerUnited States Tax Court · 1980
- Union Carbide Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1982
- Exxon Corp. v. United StatesUnited States Court of Claims · 1976
- Barton Mines Corporation, and Cross-Appellee v. Commissioner of Internal Revenue, and Cross-AppellantCourt of Appeals for the Second Circuit · 1971
5 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Louisiana Land & Exploration Co. v. CommissionerUnited States Tax Court · 1994